Prosecution Upheld for Failure to Deposit TDS on Time u/ss 276B/278B; Penalty Determination Not Required First.

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....Prosecution u/s 276B r.w.s. 278B - failure to deposit TDS deducted to govt account within the prescribed time - the petitioners cannot escape from the rigour of Section 276B - argument that no prosecution without determining the penalty cannot be accepted for the reason that the petitioners/accused have not disputed their liability and remit the TDS....